Introduction:
The Telangana High Court, in Smt. Jadi Swarupa Rani v. State of Telangana & Others (W.P. No. 7640 of 2026), delivered a significant judgment reaffirming the beneficial nature of maternity laws by holding that a woman government employee cannot be denied maternity leave for her second pregnancy merely because her first pregnancy resulted in the birth of twins. Justice K. Sarath ruled that the expression “less than two surviving children” under Rule 101(a) of the Telangana Fundamental Rules cannot be interpreted in a rigid or literal manner so as to defeat the very object of maternity benefits.
The petitioner, Smt. Jadi Swarupa Rani, was serving as a Junior Lecturer (English) in the Telangana Social Welfare Residential Educational Institutions Society (TGSWREIS). During her first pregnancy in November 2023, she gave birth to twins and was granted 180 days of maternity leave in accordance with the applicable service rules. Subsequently, when she conceived again, she applied for maternity leave commencing from April 14, 2026. During the pendency of the writ petition, she delivered her third child.
Her request, however, was rejected by the authorities on the ground that she already had two surviving children and therefore did not satisfy the eligibility condition prescribed under Rule 101(a) of the Telangana Fundamental Rules read with G.O.Ms. No. 50 dated May 17, 2014. According to the respondents, maternity leave could be granted only to women government employees having less than two surviving children.
Aggrieved by this decision, the petitioner approached the High Court under Article 226 of the Constitution, contending that the authorities had mechanically applied the “two-child norm” without appreciating that the birth of twins was a single biological event and not two separate confinements. The case required the Court to determine whether beneficial service rules governing maternity leave should receive a literal interpretation or a purposive interpretation consistent with constitutional guarantees protecting motherhood and women’s dignity.
Arguments of the Parties:
The petitioner contended that the authorities had adopted an overly technical interpretation of Rule 101(a) by treating the birth of twins as equivalent to two separate pregnancies. It was argued that her first pregnancy culminated in a single biological event, even though it resulted in the birth of two children. Therefore, for the purpose of maternity benefits, the first confinement should be regarded as one delivery and not as two independent childbirths.
The petitioner further submitted that maternity leave is a welfare measure enacted to safeguard the health, dignity and well-being of working women during pregnancy and childbirth. Such beneficial legislation, it was argued, cannot be interpreted in a manner that penalises a woman for circumstances entirely beyond her control. The occurrence of twin births is a biological phenomenon over which a mother exercises no control.
Reliance was placed upon the Supreme Court’s decision in Deepika Singh v. Central Administrative Tribunal, wherein the Court held that maternity benefit provisions deserve a purposive interpretation in furtherance of constitutional values protecting motherhood and gender equality. The petitioner also relied upon K. Umadevi v. Government of Tamil Nadu and various High Court decisions recognising that maternity benefits cannot be denied solely because the first pregnancy resulted in multiple births.
The petitioner therefore prayed for grant of 180 days’ maternity leave for her second pregnancy along with full salary, allowances and all consequential service benefits.
The respondents opposed the writ petition by relying upon Rule 101(a) of the Telangana Fundamental Rules and G.O.Ms. No. 50 dated May 17, 2014. It was argued that the Rules clearly restrict maternity leave to women government servants having less than two surviving children. Since the petitioner admittedly had two surviving children born during her first pregnancy, she ceased to be eligible for maternity leave for the subsequent pregnancy.
The respondents submitted that they were bound by the existing statutory framework and could not sanction leave contrary to the Rules. It was also contended that granting maternity leave despite the prescribed eligibility conditions would invite audit objections and lead to irregular payment of salary and allowances from public funds.
According to the respondents, any relaxation of the eligibility conditions could only be brought about by legislative or executive amendment and not through judicial interpretation.
Court’s Judgment:
Allowing the writ petition, Justice K. Sarath held that the respondents had adopted an unduly narrow interpretation of the maternity leave provisions, defeating the object of the legislation and the constitutional principles underlying maternity benefits.
The Court began by examining Rule 101(a) of the Telangana Fundamental Rules and observed that its language is substantially identical to Rule 43 of the Central Civil Services (Leave) Rules, 1972. Since the Supreme Court had already interpreted the corresponding Central Rule in Deepika Singh v. Central Administrative Tribunal, the same principles necessarily governed the interpretation of the Telangana Rules.
The Court noted that the Supreme Court in Deepika Singh emphasised that maternity leave provisions constitute beneficial legislation intended to enable women to continue their participation in the workforce without sacrificing their reproductive rights and family responsibilities. Such provisions must therefore receive a purposive and liberal interpretation rather than a strict or literal construction.
Justice Sarath observed that the Supreme Court had recognised maternity benefits as an integral component of the fundamental right to life and dignity guaranteed under Article 21 of the Constitution. These benefits also advance the constitutional directive contained in Article 42, which obligates the State to make provision for securing just and humane conditions of work and maternity relief.
The High Court emphasised that the occurrence of a twin pregnancy is a biological event entirely beyond the control of the woman concerned. A woman cannot determine whether she will deliver a single child or multiple children during a pregnancy. Consequently, denying maternity leave solely because the first pregnancy resulted in twins would amount to penalising her for circumstances over which she had absolutely no control.
The Court rejected the respondents’ submission that the expression “less than two surviving children” should be interpreted literally. According to Justice Sarath, such an interpretation would produce arbitrary and unjust consequences. A woman delivering twins during her first pregnancy would become disentitled to maternity leave for every subsequent pregnancy, whereas another woman delivering one child during each of her first two pregnancies would receive maternity leave on both occasions. Such unequal treatment, despite both women undergoing the same number of pregnancies, could not have been the legislative intention.
The Court observed that maternity leave is linked primarily to pregnancy and childbirth rather than merely the number of surviving children. Every pregnancy involves significant physical, emotional and medical challenges requiring adequate rest and postnatal care. Therefore, denying maternity leave solely because the first pregnancy produced twins would frustrate the very purpose of maternity legislation.
Justice Sarath also relied upon the Madras High Court’s judgment in J. Sharmila v. Secretary to Government, wherein it was held that the birth of twins during the first pregnancy cannot deprive a woman of maternity leave for her second pregnancy. The Madras High Court had observed that any contrary interpretation would lead to “ridiculous results” by treating multiple births during a single confinement differently from separate pregnancies.
The Court further noted that following the decision in J. Sharmila, the Government of Tamil Nadu amended its Fundamental Rules to expressly provide maternity leave for one additional delivery where the first confinement resulted in twin births. This legislative development demonstrated official acceptance of the purposive interpretation adopted by the courts.
Justice Sarath also referred to the Andhra Pradesh Government’s amendment in 2025 removing the condition relating to “less than two surviving children” altogether while regulating maternity leave. According to the Court, this reflected the evolving legislative recognition that maternity benefits should not be denied by mechanically applying numerical limitations divorced from biological realities.
The Court rejected the respondents’ argument that relief could not be granted unless the petitioner specifically challenged the relevant Government Order. It held that under Article 226 of the Constitution, the High Court possesses wide powers to protect legal and constitutional rights. Once it was found that the respondents’ interpretation of the Rules was contrary to the law declared by the Supreme Court and various High Courts, appropriate relief could be granted even without formally striking down the Government Orders.
Justice Sarath observed that in Indian society, decisions relating to childbirth are often influenced by family, social and economic circumstances, and cannot be viewed solely as the autonomous decision of the woman. This social reality had also been recognised by the Supreme Court in Deepika Singh, reinforcing the need to interpret maternity benefit provisions with sensitivity towards women’s lived experiences.
The Court concluded that the respondents had erred in refusing maternity leave merely because the petitioner had delivered twins during her first pregnancy. Since the first pregnancy constituted one biological event, the petitioner remained entitled to maternity leave for her second delivery.
Accordingly, the High Court allowed the writ petition and declared that the petitioner was entitled to maternity leave from April 14, 2026, to October 11, 2026. The respondents were directed to treat the period as maternity leave and pay the petitioner full salary, allowances and all consequential service benefits.
The judgment significantly strengthens the jurisprudence relating to maternity rights by reaffirming that beneficial service rules must be interpreted in a manner that advances constitutional values rather than frustrates them. It recognises that maternity leave exists to protect women’s health, dignity and equality in employment, and that biological circumstances such as twin pregnancies cannot become grounds for denying those protections. The decision thus reinforces the constitutional commitment to gender justice and humane working conditions while ensuring that women employees are not unfairly disadvantaged because of circumstances entirely beyond their control.